Reply to Feedback for Proposed Changes to the Pharmacy Act (Administration of Vaccines by Pharmacists)

I believe that the intended changes to the Pharmacy Act with respect to the expansion of the injection privileges for pharmacists would greatly enhance the care we provide to the public. However, I believe that pharmacists should have the right to prescribe the injections as well. This would make it more convenient for patients to receive these potentially life-saving vaccines. I understand and would be willing to participate in additional training to have the right to prescribe theses vaccines.

This makes complete sense. We now have Registered Pharmacy Technicians so have more opportunities to deliver these services. I agree that Pharmacist interns should also be able to administer injections but not Pharmacy students as they would have to do so under supervision and this would only make clients nervous.

I believe the public is ready for the expanded scope of practice. It will make the vaccination more easily available to the public.
I do not think the health system in Ontario is ready to have pharmacists prescribe the vaccines. We do not have access to patient's chart and often people do not know if they receive a vaccine or not. We require a reliable source of information to review if the patient is a correct candidate to a vaccine.
I do some injections by medical directive and I am required to advise the physician when the patient receives the vaccine so it can be recorded properly..
But I would like to receive training for prescribing for minor ailments.

Is it realistic for us to expect to only be able to prescribe if we have direct access to a chart? What if the patient doesn't have a chart established anywhere? Most patients are good historians if we do our jobs collecting a history, and we can find out what medications they are on by checking our own pharmacy records or calling other pharmacies if they go elsewhere. Prescribing decisions by physicians are made without complete charts all the time (walk-in clinics, emergency departments, travel clinics, etc.) If physicians refused to act without access to a complete chart, many patients would go without needed therapy. I agree with holding our profession to a high standard, but we shouldn't be refusing to act just because we don't have an absolutely perfect scenario for every single case. We can't ignore patients as sources of their own information, and should be able to use our professional judgment to make decisions based on the best available information.

Administration of vaccines by pharmacist makes complete sense. We already have the training and expertise to administer flu shots and the technique for these other vaccines are no different. It would also alleviate the burden from the physicians. Many patients need to take time off to book appointments for vaccine injections, whereas they could've walked into a pharmacy, got their prescription filled and injected all in one visit at the pharmacy.

Yes. We should be able to administer some common types of vaccines and B12 types of injections. We are willing to take the training. This is part of the future of pharmacy in the area of expanded scope of practice.

I would totally agree with the change. It gives the opportunity to pharmacist to provide more patient centered care. Not only pharmacist but also students and intern, it's very good learning opportunity.

I don't believe adding vaccination will be beneficial. Pharmacists have already experienced a cut to workplace hour both in terms of assistance and Pharmacist overlap. This will only add to their work load without any additional help. A stressed out Pharmacist with no breaks is not going to be able to provide the patient care that the patients should be getting.

Even though, I strongly believe the intended changes to expand the injection privileges to pharmacists is great...I do understand your apprehension...especially in corporate owned pharmacies.. this will add to the pressure (ever increasing targets, cut down on assistance and pharmacist overlap hours) and increase chances of medication errors. The college may have to look into and take steps to help ease the pressure from the managements in corporate pharmacies to achieve targets.

I agree with the workload problems. I work as a hospital pharmacist but moonlight in retail for a corporate pharmacy a couple of times a month. The staffing has been cut to the bare minimum in my opinion, but head office wants more. It seems they are trying to squeeze more money from us at the expense of medication errors or the pharmacists' health. When I work a Saturday or Sunday, I rarely get a chance to use the washroom let alone sit done for a break or eat lunch and I have a tech with me. I feel sorry for the pharmacists that work by themselves with no tech support. This puts undue stress on the pharmacist and increases the risk of errors. Isn't there some kind of legislation that is supposed to protect workers from such situations?

Don't get me wrong, I support the expanded scope of practice, but I also think corporate pharmacy needs to provide us with support for this as well.

I believe this would be a valuable and necessary change in the scope of pharmacy practice. It would benefit healthcare spending as well as greatly increase access for patients. Allowing pharmacy students and interns to administer vaccines is another great idea. It would allow flu clinics in pharmacies to run much more smoothly.

Administration of vaccines( eg. Flu) is not new for pharmacists. After proper training in Intramuscular or subcutaneous injections, Pharmacists are already doing a good job in patient care. Being front-line health care Practitioners, Pharmacists, Pharmacy students and interns should be allowed for travel or routine immunizations. Allowing them to inject other vaccines (travel as well as routine) with proper monitoring will increase patients adherence to routine immunizations as they don't have to run to and fro between Doctors and Pharmacists. It will be more convenient to Patients to directly take their yellow immunization card to Pharmacists and get their vaccinations done at one spot. Although it might increase the work-load on Pharmacists, but as with expanding scope of Registered Pharmacy Technicians, the work-load on Pharmacists can be delegated/divided. Also at the same time, the workload (stress) from the shoulders of Doctors will be lowered a little. I would like to highly recommend this new opportunity to be given to Canadian Pharmacists.

It is fine for pharmacists to administer vaccines covered by the public health program. I would be hesitant on the specialty vaccines such as typhoid, yellow fever or Japanese Encephalitis. Travel medicine is a specialty within the medical profession. Medical schools in Europe provide courses for medical students to be specialists in travel medicine. It is much more detail then most pharmacists thought.
As to students and intern allow to inject is definitely No!

Agreed! I would have no problem with pharmacists administering vaccines covered by the public health program. However I would be reluctant to administer the specialty vaccines such as typhoid, yellow fever or Japanese Encephalitis and specialty travel vaccines as it would take some time to ascertain whether these were indeed indicated in a particular patient as travel requirements and recommendations continually change and are updated by the CDC. I also agree with those who are concerned about the added workload that this would put on pharmacists. In spite of the fact that pharmacy technicians can now be regulated and perform many tasks that "should" allow more time for clinical services such as this, the reality is that many stores do not have the resources to hire one. Before administering a vaccine it is imperative that we ascertain the appropriateness of it in any individual and the additional time that it takes to do this will likely take us away from other patients. Could we hope to receive adequate financial compensation for these services -- that is, adequate enough to pay for additional support staff to allow for the time spent? (In reality, most patients are not going to make an appointment for their vaccine and come back at another time even though this would be ideal!). As well, what about pharmacists who do not "believe" in immunizations? While I absolutely do personally, and am certified for injections, I also work in two different community pharmacies one day a week (each) where the owner/pharmacist does not believe in immunizations in general. How would this look or be explained to the public?

Travel medicine is a specialty and requires designated professionals to be knowledgeable enough about Purpose of injection, Necessity of the vaccine, Required number of injections in a series, Dealing with missed or late doses, Severity of side effects (Especially from live vaccines), Contraindications to each vaccine, Documentation (Yellow Fever Certificate), Follow up with prescribing physician etc. There is too much room for errors to occur when the person prescribing these vaccines is not working closely with the person administering he vaccines to ensure the patients best interests are met.

Given that this legislation change would not allow Pharmacists to prescribe travel-related vaccines, I believe your concerns re: knowing when this is appropriate, etc. would be addressed by having a competent travel vaccine prescriber.

Pharmacists are already overwhelmed with the workload and expanded vaccine services would create additional pressure. The new burden is going to negatively affect our focus on dealing with Rxs and the associated drug related problems.

Having done my training out in BC back in 2013-2014, I saw that the pharmacists were administering ALL shots. Brought up the question, why isn't Ontario doing this? If we truly wanted to cut health care costs, then this an expense we can reduce from the doctors, and have the pharmacist administer for a smaller fee. I think it's a terrific idea. Why does a patient have to go and wait an hour for his/her appt just to get a shot? Why does a patient even have to make an appointment in the first place? It's just a vaccination. It's not a procedure, or surgery, it's just a vaccination. So please, the quicker you make this 'amendment', the better. I'm not sure why Ontario is 10 years behind than all the provinces. Come on people, let's actively make our health care better and more efficient. The budget will love it, the doctors would get more relief, the pharmacists will be somewhat satisifed there's another way to increase revenues, on top of all that, the 'public' that you so love to protect more than us, would be much more appreciative that they don't have to go through an MD to get their shots. Anyways, thank you for reading this! Cheers,

I believe it is a great idea. I was trying to get medical directives for vaccine injections from the nearest doctor's office to no avail. Some of our patients are taking days off from their work in order to get vaccinated. Why is the process of getting a vaccination so complicated in the 21st century?

I totally agree with you except the "smaller fee". All the vaccinations need considerable time. It does not fit well in the current workflow of a community pharmacy except we get a significant rise in fee for that.
It is wonderful to have the opportunity to serve the community. It will be a huge uplift of our profession. But to make it sustainable we have to earn more revenue. As for example, we can run clinic days with dedicated pharmacists. Certainly, we need more money for that!

It is a great step to prevent many infectious diseases and establish a strong herd community. Pharmacist should NOT only able to administer but also assess and prescribe a vaccine as per most current Canadian Immunization Guide. Serious vaccine-related adverse reactions are rare (<1%) but pharmacists should be adequately prepared should they arise.

OCP must ensure that the immunization is carried out in the best interest of a patient and not in the financial interest of the organization by whom the pharmacist is employed. Any activities of dubious nature and against professionalism should be monitored and if appropriate be penalized. OCP should ensure that the vaccines are given in an environment that protects patient's privacy and confidentiality. OCP should regularlyupdate members of the college for audits and investigation. Finally, OCP should establish an anonymous forum where the members can bring concerns related to vaccine administration if they are going to jeopardize patient care or put the patient at increased risk of harm.

I believe that the intended changes to the Pharmacy Act with respect to the expansion of the injection privileges for pharmacists would certainly increase care we provide to the public. I do not agree with pharmacy students performing the injection but I do feel that a pharmacy intern is capable. I would be happy to participate in any training required to allow pharmacists to prescribe vaccines as well. I believe this would be beneficial to our health care system.

I believe being eligible to do vaccination training for an increased number of vaccines would be excellent for the profession. Doing so would increase our value and advocacy to society. Most importantly, we would take the buren off of the health care system and improve the quality and workflow of the health care system. I am all for this.

If I can give influenza vaccines, I am not sure as to why I currently can only give other vaccinations under a medical directive. It seems silly to dispense things like twinrix for patients to then take back to the prescribers office to have administered. It should all take place at the pharmacy.

This is an excellent step forward in utilizing pharmacist's clinical skills. I would also like to see authorization for vaccine certified pharmacists to administer B12 injection which are a common reason patients attend a doctor's office and often may use up a visit that another patient may be more in need of, simply for that reason alone.

Pharmacists should have both the right to prescribe vaccines (with yellow fever being a certified exception) and inject vaccines.
Pharmacists should also be able to inject (and bill for the injection) vitamin B12 injections.

As a pharmacist practiced for 2 years in BC administring all kind if vaccine i would love to see ON have the same regulation in terms of administration of vaccines as in my opinion same injection techniques apply and would be more convenient for patients as all noticed with the flu vaccine.

I feel this is an excellent proposal and it will positively benefit the health of the public. As shown by the wide spread success of the influenza program, allowing pharmacists to inject other vaccinations will greatly improve vaccination rates, which have been on the decline recently. Pharmacists are uniquely positioned to educate patients and my personal experience has shown that we are trusted often more than doctors around vaccinations/medications. One major issue will be coverage of payment around these vaccinations, should the government be willing to cover the costs of them I can see this being a very successful endeavor and one that will bring a large amount of cost-savings to the public health system in the long term.

I agree with the proposed changes as there is no difference between the administration of these vaccines and the flu vaccine. Both are intramuscular injections.

Also, as long as students and interns are trained, insured and are in good standing with the College, they should be allowed to administer vaccines. As long as the training is completed, in principle there is no difference in the capabilities of an intern or student from an RPh.

Your comment that all these vaccines are "Intramuscular" only proves the point that not all pharmacists are prepared for this responsibility and the risk of errors like this being made are detrimental. Yellow Fever vaccine is actually a Subcutaneous injection and improper injection may end up fatal for the patient.

I think it is the logical next step in enhancing our ability to service our patients. It is more convenient for the patient, better preservation of cold chain and a reduced pressure on the health care system provided that we are given adequate reimbursement for this service.

Vaccines is something that Pharmacists are educated on and have the capacity to do. Given the convenience for patients it's a no brainer that this would be beneficial for health care as a whole. My concern has to do with the remuneration of this. The value of Pharmacists is absolutely diminished in comparison to what other health care professional make for administering flu shots, I hope that the same does not happen for the proposed vaccines. It would help to justify and support Pharmacist overlap and workflow issues associated with administering vaccines. Unlike flu shots, these vaccines should not be a loss-leader. Pharmacists are worth more than that.

This is a step forward for our profession. However, it's somewhat confusing that pharmacists are not authorized to prescribe the selected vaccines as they belong to Schedule II Rx. Does this requirement only apply when patients have drug plans. I wonder if it would be legal for the pharmacist to administer appropriate vaccines to cash-paying patients who request the vaccination?

There should be pharmacists who are dedicated to injections only. I can see how certain commercial pharmacies will jump on the opportunity to make pharmacists push these vaccines and not give extra technician or pharmacist support, same as flu shots. Also, we need access to patient health data and vaccines given, few people know what they already had accurately, and it makes sense to record the vaccines in a unified electronic chart. Also, access to their chart to look at contra-indications and indications. Otherwise, how are we going to really make sure it goes in a patient's record? Write in the yellow card, if they have one would make sense.
Travel vaccines- makes sense, but we don't have the proper training, would be a good idea for those who don't know to have a special course about travel vaccines, again, not hard, there are online ces about that already. Also, what will happen to travel clinic physicians? OCP needs to talk to them, otherwise we are treading on their turf and they will see it as that. Who will prescribe the anti malaria and anti diarhhea drugs, who will figure out if you need yellow fever vaccine? How is it recorded? Why would people make two trips to a travel clinic and to the pharmacy for the shots? It would make sense if these pharmacies were working with the travel clinics or were next to them.

Also, I would want a closed consult room for certain vaccines - I don't want to discuss patient info in an open corner of the pharmacy or have people scream from the yellow fever vaccine in plain view (it is quite painful).

I have no problem with interns and students doing shots, they took the same course as us, and we all had to 'practice' on our first patients anyway, it would be better if they gave their first shots as students, it's not that hard as a skill but you have to learn it on people, with someone who will give you pointers and tips, not on sponges.

Absolutely in favour of the regulations. I believe that we should also be able to prescribe the vaccines as well. Specialty travel vaccines could require ISTM certification to prescribe possibly. I also give many b12 shots under medical directive currently. These as well as other regular Injectables ( ie Prolia) should also be included.

This initiative should not go forward until OCP first surveys a large number of registrants to determine if they really want to do more injections...a technical function totally unrelated to their educational/knowledge skills. This initative is largely being promoted by Big Pharmacy Retail as a means to create more store traffic and enhance the sales of general merchandise. I submit that the majority of pharmacists do not want to do injections of any kind and that they have been railroaded into this by special interest forces.

I completely agree that pharmacists administer vaccines and that students/interns do so as well. I have already been giving a few vaccines such as Zostavax and Twinrix under a medical directive. This would greatly enhance care. Patients are already asking for them anyway! I also think pharmacists should prescribe them, especially if they are already doing travel clinics.

I think having pharmacists administer additional vaccines is a great idea in general. However, I do not feel comfortable immunizing against yellow fever, typhoid, Japanese encephalitis, or rabies. I also believe that if this service is offered at pharmacies it should be on an appointment basis to ensure that the proper time is set aside to discuss the vaccine and provide the vaccine to the patient. I also think a refresher on administering SC vaccines would be essential before this service could be offered at the pharmacy.

I believe that the intended changes to the Pharmacy Act with respect to the expansion of the injection privileges for pharmacists would greatly enhance the care we provide to the public and would be a great step in strengthening Pharmacist-Patient relationship. However, I also believe that with the proper Education and additional Training provided, pharmacists should be able to prescribe the Vaccines as well. This would make it more convenient for patients to receive these potentially life-saving vaccines without the hassle of seeing their family Doctors and would definitely decrease the workload for Physicians at the same time.

I think it's great the College is increasing the number of vaccine's pharmacist's are able to administer. I am all for this as long pharmacists will be adequately compensated for the increase in scope. However, being unable to prescribe something like a TwinRix is unfortunate. This will still involve the physician if a prescription is required. Perhaps having a small list of vaccines that can be prescribed (Zostavax, Gardasil, havrix and twinrix) vs. cannot prescribe. I would also expect some sort of course for the pharmacist to take in order to be appropriately qualified. I also feel only pharmacists and interns should have the ability to administer injections.

As a pharmacist, I couldn't agree more to expanding the list of vaccines we can immunize. A lot of patients are asking why we cannot give them the vaccine which is dispensed at the pharmacy itself. Pharmacists have been trained to successfully administer vaccines and can further help reduce the burden on the health system and save time for patients and their families.

On the flip side, the reality of current community practice cannot be undermined. With labour hours cuts, lack of overlap, lack of breaks (my most days are 12 hour work days with no structured breaks), and insufficient space to administer these services, it makes it challenging to deliver these services.

It is disappointing that some pharmacists comments show they just know nothing about travel vaccines and how critical they are if the proper training is not provided.Patient care and safety should not be compromised by just increasing script count and revenue .These vaccines should only be given by travel doctors

The legislation does not allow pharmacists to prescribe the vaccines - they would still be prescribed by a physician (hopefully a travel physician, although many family docs order these too without any additional training). The legislation only refers to the task of administration, which many travel docs delegate to nurses anyway after providing the order, so I don't see why it's an issue. You mentioned that some comments here suggest that pharmacists don't understand travel medicine and are doing this for business purposes. Your statement suggests you don't fully understand the legislation you are commenting on either.

I fully support expanding the list of vaccinations that pharmacists can provide. As the most accessible health care professional, pharmacists can play an important role in improving public health by increasing vaccination rates. This list is, however, incomplete and notable omissions from the list such as tetanus and pertussis should be added.

many patients asked me to administer vaccines like Twinrex and varicella and it should have been already
there years earlier.
Please go ahead and do the change for better patient care and optimum use of pharmacist knowlege and expertise.

I believe giving an injection is a purely technical skill not a clinical skill. Registered Pharmacy Technicians should be authorized to give injections to allow pharmacists performing their clinical duties. Pharmacists should utilize their time in counseling, checking Rx, medscheck, communicating with healthcare providers and prescribing for minor ailments. Pharmacists should not waste their time in technical issues like giving injections. It is more cost-effective for a registered PA to give injections than the pharmacist.

The idea is great. However, we will only be expected to do this by our employers with no additional help. I have been working through flu season year after year without additional tech hours. Added duties and no additional help, a dispensing error is more likely to occur.

I welcome this new move. Now, how do pharmacists make sure they know enough to inject these vaccines safely, and follow up patients & prescribers properly? It is likely that many pharmacists need help in obtaining necessary knowledge, maybe in a form of seminars. By the way, why can't I post my injection training certificate on OCP's website?

I think this would be a benefit to the health care system by taking the burden off the health care system. However with these additional services pharmacist should be billing the government directly as opposed to the pharmacist providing the service and the pharmacy chain being paid for the service.

I am firmly in favour of pharmacists being able to provide greater access to immunizations, however these regulations fall short of truly increasing access as most of the vaccines listed in table 3 are Schedule 1 products and require a prescription, and therefore the prescribing and the administration of these products are separate acts. The way the regulations read currently, pharmacists will only be able to administer these vaccines if the patient presents with a prescription for the schedule 1 product and that without a prescription written by an authorized prescriber, pharmacists will not be able to initiate immunization for the patient. Influenza vaccine is a schedule 2 product, so being able to merely administer the vaccine did not present a legal issue, however with schedule 1 products, the patient will still need to visit a prescriber). With the current wording of the regulations, the only vaccinations that can be administered in pharmacy without a prescription would be Haemophilus influenzae type B, pediatric Hepatitis B, and pneumococcal (conjugate and polysaccharide). Moreover, pharmacies will not be able to become yellow fever designated sites and order vaccine as pharmacists will not be able to be the site's designated health care provider without the authorization to prescribe the vaccine - they would need to have a collaborative relationship with a prescriber as the pharmacist cannot be the designated HCP even with a medical directive. This means that very few pharmacies would ever be able to actually purchase or administer yellow fever vaccine. I see these as huge drawbacks to the changed regulations as it "sounds" like patients will have better access to vaccines, but they truly will not. It is often the patient assessment & prescribing of the vaccine that is the barrier to access, rather than the administration itself.

I feel that it would be a burden on the pharmacist to administer more injections especially as we are already quite busy with patient counselling and meds checks. It is quite difficult to stop what you are doing and administer an injection.

I totally support this amendment. Many patients come to pharmacy and requesting that to get their vaccine injection by pharmacist. They find that more convenient specially when the pharmacy is open for extended hours and during week ends. Currently we still injecting with medical directive and direct orders.

I've been a pharmacist since 1978. In the last few years I've noticed positive changes allowing retail pharmacists to become more clinical and involved with patient care, thus using the knowledge obtained after ++++ years of university. More importantly I long for the day when pharmacists get more public recognition involving patient's healthcare. If vaccination shots are the way to go, I am all for it. The vaccines are there to be dispensed, it makes since for all invoked to have it administered at the same time. Hopefully the compensation will go to the professional and not the conglomerates.

Yes, this would definitely be a step forward to improve convenience for patients and allow pharmacists to put their skills and knowledge into practice. It would be more helpful if selected vaccinations can also be prescribed by pharmacists and I would not mind taking an additional training for such.

Administration of vaccinations by pharmacists will help to expand patient care and reduce health care costs in Ontario. Would love to see pharmacists able to prescribe as well to streamline this process and make it easily accessible for the patients.
Very excited about this possibility!

I am supportive of increased vaccinations, however I think that the following would be helpful:
1. Cheaper injection classes, but mandatory refresher courses every few years (Like First Aid certification)
2. Being able to give selected antibiotics when required. (The only one I am thinking of is Ceftriaxone IM for Gonorrhea, there was a time when Cefixime was unavailable, and IM Ceftriaxone is the first line treatment as recommended by public health, however the treatment is very hard to access outside of special sexual health clinics)

I find it puzzling as to why this discussion even needs to occur. One can only assume it was politics that prevented us from injecting anything except UIIP-covered flu vaccine, as opposed to any real concern about public health. If I can inject flu vaccine, what clinical argument could there possibly be to prevent me from giving virtually any other vaccine to a patient? How is the interest of the patient served under that scenario? There is no therapeutic or clinical reason that we should not have had this scope of practice from the outset. With that said, I have been injecting most vaccines under direct order/medical directive since our authority was established in 2012, so clearly I am in favour of the expansion. I am pleased to see that interns and registered pharmacy students are being considered, however I think the college should take it one step further and start the process to allow Pharmacy Technicians to administer vaccines. In truth, injection is a technical act and the skill set of the pharmacy technician is more than adequate to allow this, with proper injection training of course. Although I believe patients are better served by having access to flu and other vaccinations, Pharmacists are now stuck jabbing people every fall, instead of managing drug therapy, which is what they should be doing. It would show great leadership by the college to move in this direction.

I extremely welcome the expansion of this valuable and much needed service. All patients and the health care system itself will be benefited. However it will make broader sense to include prescribing authority by Pharmacists as well. There is no diagnosis needed to prescribe vaccines then why do the patients still have to book an appointment with a doctor and wait till they get prescription!. I am a strong believer of common ailment program already being run in other provinces and countries. Why Ontario is so behind?

I also, totally agree with the proposed regulations expanding our scope of practice to provide vaccines other than influenza vaccines to the public.
I also would like to see 'prescribing for minor ailments' added to our scope of practice.

This is an excellent public health initiative but why is this a limited list? For example, The Tdap (tetanus/whooping cough/diptheria) boosters are missing from here and are key adult vaccines, especially with recent outbreaks of whooping cough. Adults often need the Tdap booster after a self-limiting injury (tetanus) or when they will be around a new baby (grandparents/whooping cough). Pharmacists could boost these rates and raise awareness.

Also, it is great to see students included as they are trained and certified in school but cannot practice their skills until after they are licensed. If anything, this delay weakens their skills.

I am all for and in support of pharmacists expanding their injection skills to theses other vaccines, however, I am seriously concerned with the amount of money we will be reimbursed to perform these extra duties. I look to the Flu Vaccine program as a perfect example. I was all for pharmacists administering flu shots but when they announced the fee they would reimburse us, I immediately had second thoughts. We, as pharmacists, are saving the health care system hundreds of thousands of dollars (if not millions) to administer the annual flu vaccine for such a ridiculously low fee. Actually, it's insulting. Physicians don't do anything differently yet get reimbursed many times more than we do. As pharmacists, we should come together and REFUSE to do these flu vaccines and let the government spends hundreds of thousands of dollars more like the good ol' days. In summary, i agree with pharmacists taking on these extra vaccines but we MUST get reimbursed what physicians get reimbursed else we are selling ourselves short.

I'm very supportive of expanding the services pharmacists may provide to their patients. BUT I don't believe being able administer additional vaccinations is a good use of our time, clinical knowledge and expertise. Working in retail, I find it would be nearly impossible to have the time to effectively and safety incorporate such services, in addition to performing our primary duties within the pharmacy. There are many healthcare professionals that are able to provide vaccinations and I believe allocating these services to pharmacists would be highly demanding and unnessesary. As for students/interns being permitted to provide vacccines- NO.

I strongly agree with the proposed changes. Since we started doing flu shots we have had many patients in asking us to do their travel vaccines as well. Injections at the pharmacy has been widely accepted by patients and the waiting period afterward provides us with an added opportunity to discuss other health matters with patients we may not normally see or do not qualify for MedsCheks. I believe many patients would be more likely to get their vaccines if they didn't have to make an appointment with the doctor. I think this is a great service we can provide, however, remuneration would have to addressed as well.

I agree Ontario pharmacist should be allowed to administer vaccines other than the flu vaccine without physician permission. The physician writes the scipt, so they are authorizing the medication. It is certainly simpler for the pt to have the medication injected at pick up in the pharmacy. I agree that pharmacy interns should be allowed to administer vaccinations, however I'm not sure pharmacy students should be allowed at this point

No doubt this will greatly improve patient care and will help in disease control. I would say yes that this amendment should go ahead. But I have one concern that if a pharmacist is working for a chain, they keep all the money paid to the pharmacist for injection administration and don't even offer any single penny. Not only that, they don't even pay for the time spent in the 2 day training to maintain CPR. I would suggest college to do something for the pharmacists by putting a condition where chain pharmacies should share some money with the pharmacists too. Otherwise, it will consider more of a burden because chains will increase their pressure to do injections.

I do not support the immunization amendments. There are already lots of responsibility that a pharmacist needs to handle. Some pharmacists are being overworked. Also, this is relatively new practice. Unless the pharmacist would get educated on the immunization for free and that all pharmacies have pharmacy technicians as staff instead of assistants, I would think this change would be too soon. Until it is mandatory for all pharmacy staff to be registered (meaning no longer have pharmacy assistant), I do not support this practice. Patients would have to wait either way, and the fact that there is more responsibility, this can increase the risk of errors. I believe it would be less stress for the physicians to provide injections than pharmacists, because physician see one patient at a time while pharmacist needs to multitask. I believe doctors should provide these injections and not pharmacists. What i suggest is to have a pharmacy that specialize in providing injections.

I completely support this proposal however, I believe that we should also be fairly compensated for this enhanced service. Ontario should review the vaccine administration models adopted by pharmacists in Alberta and other such provinces.

Every day i hear from my patients why we are not allowed to give other then Flu vaccinations. The government will save a lot of money by having pharmacists give vaccinations. In this deluded system the patients have to make an appointment with the MD, come to the pharmacy to get Rx filled then take it back to have the injection. In all due respect this does not sound like a very efficient system. I think the OCP is doing a great job in putting this case forward. Pharmacist in US have been doing it for years, come on what is the delay? I think it should be implemented today. My personal view

I think this is a terrific idea to alleviate the burden on physicians in our healthcare system and save the government millions of tax dollars. A lot of patients ask if we can administer flu shots, why not anything else? Pharmacists in Alberta, Saskatchewan, Manitoba, New Brunswick, PEI, and Newfoundland already have the authority to administer any vaccine. It makes sense that Ontario would follow what's already been proven to be effective. However, I do understand the added workload to community pharmacists, so the government should provide enough compensation to the pharmacist/pharmacy to consider Pharmacist shift coverages to allow for this service to function. I also think that pharmacists should be given the authority to assess and prescribe travel vaccines as well to provide optimal patient care. How much time and money is actually saved if the patient still has to wait 3 hours to see the doctor, get a prescription for the vaccines, then come down to the pharmacy to get the vaccine? If the pharmacist is trained to assess (which would be compensated by the government) and given the authority to prescribe, then the government will save money, the patient would save time, and the pharmacist would be able to help out the burdening healthcare system.

I am in favour of the scope expansion. In order to improve patient access to care and impact health care costs, it makes sense for pharmacists to prescribe these vaccinations according to standards of care. Perhaps that is the next step in order to satisfy the concerns of the medical community regarding pharmacist professional image.

I agree with this proposed change. This will increase access for patients and prevent need to return to physician office or clinic for administration of vaccine once dispensed by pharmacy.
This will be a great change for Ontario.

I feel that pharmacists in a retail setting are spending too much time on flu vaccinations and not making use of regulated techs who could full the gap. Retail pharmacies are reluctant to pay registered techs commensurate to their new expanded role and responsibilities. When I go to pick up a prescription, I am informed that it will take upwards of 4 hours at a minimum. This is unacceptable when a patient is in pain or a parent requires an antibiotic for a sick child after a long wait in an emergency room. Expand the role for more injections only if registered technicians can be paid what they are worth.

This would be a great idea as long as there is a firm of compensation. We far behind other provinces when it comes to pharmacy services for things like vaccines, minor ailments and so on. However there has to be fair compensation. Personally I didn't get the flu vaccine in my pharmacy because it would've upset the physician I'm working with and with my work flu it wasn't worth the 7 dollars. Many places I know had to hire an overlapping pharmacist which again is extra cost not including fridge costs and increased liability insurance. More importantly than injecting pharmacists should have the ability to prescribe it also. It makes no sense for the patient to pay for a travel clinic and then come pay you for a shot. They can pay for both at one place. Overall it's a great idea if done fairly and in a convenient way. Pharmacy can't afford to be working for very low wage or offer any more free services.

Increasing the number of vaccines a pharmacist can administer will benefit few people.
We can't focus blindly on what may be good for the patient when it may be detrimental to the pharmacy.
There must be a balance between benefit to the public and benefit to the business.
It is challenging enough to provide flu vaccines in the current pharmacy environment.
Labour cutbacks make it difficult to maintain the current level of Pharmaceutical Care provided.
The pressure on pharmacists to administer the flu vaccine increases the workload without providing appropriate compensation.
Many people who request the flu vaccine do not come prepared with regard to time or dressing appropriately.
Such people do not view vaccinations as the medical procedures they are, and wrongly expect the process to be as easy as buying candy.
It is unlikely that anyone seeking advanced levels of vaccination will be better prepared.
Travel vaccines and other vaccines require a more detailed history of a person's vaccinations.
Most people are not aware of their vaccination history, especially regarding any vaccines received as a child.
From personal experience, vaccine history is not properly shared between family physicians and the local Health Unit.
Further, I am not aware if such information is shared between different Health Units within Ontario.
Without an accurate and detailed vaccine history, a pharmacist cannot properly assess the needs of the patient.
As far as Travel vaccines are concerned, the HCP must perform a detailed consultation with the patient to determine their travel itinerary, and must be aware of risks associated with those areas. These services tend to be provided in specialized clinics, as they are not commonly provided by GPs.
In addition, it is not enough to provide vaccines; often a prescription for an anti-malarial or altitude sickness therapy may be required.
These are not within the pharmacist's scope, so the patient will need to visit a Travel clinic regardless.
Most pharmacies will likely not even stock such vaccinations, as they will be used too infrequently to justify the cost of keeping stock on hand.
If pharmacists want to provide better care to patients, then we need to focus on supporting the Pharmaceutical Care that we already provide, and are specially trained in like no other profession, rather than trying to take on the responsibilities of other health care professionals.

Thank you for your excellent feedback. I agree that expanding more injections will cause more strain and I doubt the government will even pay us to to perform these vaccinations, they will expect patients to pay for the convenience. I would much prefer minor ailment prescribing like other provinces have, this is more in line with our clinical skill set. Seriously if a chiropodist can prescribe canesten cream, pharmacist should be able to as well.

As a pharmacist administering multiple immunizations (e.g. Zostavax, Gardasil, Twinrix, Havrix...) under direct medical orders, and the annual flu shot, I believe the proposed changes would be excellent to offer even better patient care. Many pharmacists have already receive the necessary training to administer injections, thus it only makes sense to use these skills to free up physician's valuable time. It is so much more convenient for patients to receive their injection at the pharmacy at a pre-determined time instead of having to return to the doctor's office at a later date for the administration. As for students and interns administering vaccines, I am more reserved as this could pose a liability issue should a mishap occur.

Yes I would love to vaccinate my patients because I feel capable enough and knowledgeable to do so. Vaccinating will be greatly appreciated by my patients and it will also make it more convenient for them.

Love the idea! Makes complete sense to expand to other vaccinations. In discussing travel vaccinations with other allied healthcare professionals, they were relieved to hear we may be able to do them. Travel vaccines are very time consuming for them - the initial consultation, determining appropriate vaccinations, injection and recouping payment from patients. We're in a good position to take that on.

I do not think letting pharmacy students or interns to administer any vaccines is a good proposal. No matter what their level of training is, because another pharmacist is responsible for them, they should not be given this authorization! Only trained pharmacists should be able to administer vaccines.

An excellent opportunity to expand upon the injection training we have, and a natural growth for the profession of pharmacy. This should be accompanied by the ability to prescribe these vaccines in order to really improve access for patients and use our expertise in medication management to the fullest.

After successful administration of influenza vaccine, I think now is correct time for profession to provide this valuable service. After additional training, they should allow us to write prescription for certain vaccines too. Totally agree with the change.

I see this step is very important to improve patient's care, provides easier faster access to vaccination. I see as well that our scope should include vitamins as B12 shots and Depo-Provera, I don't see why not! In Alberta we used to inject all sorts of medications

This is great news. It will greatly improve patient care because they do not need to wait at the doctor's office for a long time and risk exposing themselves to germs carried by other sick patient., especially for the senior population.

This is absolutely a good advancement in the already expanding scope. We are vaccinating already and this makes sense as most of the time we know what patients are best candidates for certain vaccines.
Having said that, this should also come with the need for pharmacist reimbursement. Its already a tight day for a pharmacist, and adding these would make it even more tough. Pharmacist should be pain to give these vaccines. Infact we should be given authority to prescribe these too.

I completely agree with the regulations put forward to administer vaccines to the public. Access has been an ongoing issue in Ontario and this can definitely help to improve it. I would also like to see Ontario Pharmacists able to order specific lab tests so that we can continue to provide patient-focused care.

I think it would be more appropriate given our background and training to obtain expanded scope for more clinical-related responsibilities (ie. prescribing). Pharmacists should build competency and further their skills in being medication experts, not medication administrators. Vaccinations are a very technical skill that will take even more time away from the front-line community pharmacist's role in checking prescriptions and managing drug interactions/optimizing drug therapy. That being said, maybe I would be less against it if the working conditions were better. Currently with BPR taking up so much of the market and so much focus on cutting hours/labour, it would be hard to manage so many more responsibilities without corresponding increase in labour/staff help.

I support the vaccination administration amendment for the following reasons:
- No additional injection training beyond current injection training is required
- The stability of refrigerated drugs are less likely to become compromised between leaving the controlled environment of the pharmacy and the time of administration.
- a patient's condition is much less likely to change within the time the prescription is processed and the time of administration (eg. The patient may develop a flu with fever in the days leading up to their doctor's appointment and thus require additional assessment for appropriateness prior to injection)
- preventing the pharmacist from writing a prescription still allows for the double assessment of the patient by a physician and pharmacist (best practice)
- patients will have faster and more convenient access to vaccination, thus also reducing time restrictions on travel to affected regions
Thank you.

I do not believe that pharmacists should be giving anything other than a flu shot. They are not trained in emergency medicine in case someone has a reaction. At least in a doctors office they know what to do and so do the nurses. Pharmacist and Technicians should not be placed in this situation. Community pharmacies are cutting back technician hours. Where are they supposed to find the time? It is already hectic and understaffed during flu shot season.
Even if you mandated that they must have desognated Technician hours I would personally not feel safe going to a Pharmacist for anything other than a flu shot. That is why we have Health Units and trained medical personnel.

Pharmacists have demonstrated a benefit to the people of Ontario by increasing the number of locations for influenza injection especially to those who lack family physicians and those in under-serviced areas. A further expansion of services can continue to benefit the people of Ontario by providing the services that they're already requesting. When the influenza vaccine was rolled out there was a lot of education related to the vaccine beyond injection technique. I'd like to see equal levels of education provided for the other vaccines, so that all pharmacists with injection accreditation will feel equally comfortable administering these new vaccines.

I'm glad to have this opportunity to expand my scope of practise especially allowing us to help students and interns build their confidence with these additional tasks that add more value and convenience to the services offered by pharmacists

This is a total no-brainer. Pharmacists administering flu shots has been an overwhelming success by anyone's standards and has shown the huge potential that expanded scope can realize. Making health care more accessible to patients via highly trained highly skilled professionals -how can that not be a good thing?

This would be great and an expected extension of our professional activities given we are currently administering flu vaccines. We have the numbers and track record with the public and practitioners that pharmacists are able, capable, and willing to do this. To expand our scope more with similar vaccines would be a natural progression of our responsibilities I would think. I am very excited and looking forward to the time I can give other vaccines to my clients in the pharmacy.

Although the list is fairly comprehensive, I would suggest to add some common vaccines that are missing: Tetanus vaccine and the Measles, Mumps, Rubella (MMR) Vaccine. Perhaps in one line, you could indicate: measles, mumps, rubella, and varicella vaccines.

Yes agree to expansion, however, would like to incorporate simple tear off sheet explaining more about the individual vaccine, precautions for travelling, Rx brief case has a very good article. I believe all Pharmacists should first get a refresher course and Continiung education about each vaccine. Then make counselling MANDATORY controlled by OCP. Otherwise Chain stores will try to just make money out of this professional expansion and they will not put proper allocation of funding and resources, there attitude would be similar to how medschecks 5 min in and out philosophy. OCP must control the outcome from the very start so that it doesn't become another business add thereby disrespecting patients. Yes my comments are harsh but no-one can argue that it is not the Truth.

This expanded role is an excellent idea but we definitely need more training. I worked in USA for a few years and vaccinations and B-12 shots were part of the routine work. However we all had to attend a two day training course that covered injection techniques and vaccine information

I am 100% behind this initiative. I think we need to continue to make health care more accessible for the patients. I would like to see assessments and prescribing of vaccines included in this change. We all need to move forward with increasing our scope of practice

I believe it will be a great Oportunity for Pharmacists to be able to give most common types of vaccines as we already got the training and the ability to give flu Vaccines . This will reduce the pressure on Doctors, as well as on patients who sometimes take off time from work in order to get the vaccines at Doctors office

Improvement in care for patients and an advanced scope for pharmacists is a win-win situation.
Wish for full scope to prescribe and administer all vaccinations with NO list. Pharmacists are capable..so let's just do it!

I am in support of this proposed act and hope it gets passed as soon as possible. I am in favour of any additional training needed to provide the best possible care for our patients when administering these vaccines.

I really welcome the change
I am administering these vaccines under medical directive-direct order from the relevant physician but some physicians do not understand the procedure and are not ready to part with the delegation plus it is a time consuming procedure
The amendment will definitely make positive difference in the patient care and will project positive image of the pharmacist in general
I am personally happy about this amendment

I don't agree with the idea as it will interrupt the regular flow of Rx's and add extra stress on pharmacists . Knowing the patient's previous medical history is very crucial when administering such vaccines and this information is only available to their family physician ,especially if the patient requesting the vaccine is not a regular patient for the pharmacy

If we can already give flu shots, why can we not give other vaccines? Of course the training would be essential, but it is not difficult for someone as highly trained as a licensed pharmacist to learn the requirements of administering various vaccinations. There is also the question of reimbursement. Many pharmacists are taking on additional responsibilities without getting any additional pay for those responsibilities. If we are giving the same vaccination as a physician, should we not be paid the same amount? With respect to students giving injections I do not believe it is a good idea to allow them to give an unlimited number of injections as chains and independent pharmacy owners may use pharmacy students and interns as workhorses to provide huge numbers of injections to pad their pockets. Instead, students and interns should be able to provide up to a certain number of injections during their training in order to demonstrate competency, but not to be forced to give injections during their entire shift for multiple weeks at a time.

My mind is divided on whether this will be beneficial to the public & the profession.
1. Pro-amendment: I believe that pharmacists have the necessary skill to do this, and it would lift some burden from the GPs.
2. Anti-amendment: pharmacists face real challenges at the workplace with cut hours (both pharmacists and assistants) and corporate head office will pressure pharmacists to offer vaccines as a walk-in, simply adding in the new duty to workflow. This will simply cause pharmacists to be more overloaded than we already are, and mistakes happen when we are stretched beyond our limit. May not be an issue for slower pharmacies, but busier pharmacies will feel this- and blame will always fall on the pharmacist when they make a mistake, or fail to meet our promise times, to simply "manage our time better"

This is a great idea that is long overdue. If you evaluate other provinces, pharmacists have been providing this service for some time now. However, we need to have the ability to prescribe besides administering, hopefully we can use this as a launching pad. Finally, lets think about other routine adult immunization boosters like tetanus etc.

I am to support Administration of Vaccines by Pharmacists, based on my experience with giving flu shots, patients find more convenient to deal with their pharmacist rather than booking appointment to see MD and the wait at the pharmacy not to be compared to MD office.
It can be a rich opportunity for pharmacists for CE to educate their patients about the importance of vaccines.
Business wise I expect worthy profits specially if pharmacists were able to show professionalism towards the service.
Let's gather efforts toward Ontario free from infections.

Absolutely agree with the idea of Pharmacist administering all vaccines. I get that question from my patients so frequently "why pharmacist can't administer other vaccines?" it will be so much more convenient for patients and gives them better access to it as they don't need to wait for their appointment.

It will be very good to be able to do all kind of vaccines. I hope by doing that we will see less cuts being done to the pharmacy sector so we can afford more technicians hours or pharmacist overlap as needed. We sure should include vitamin B12 injection to this list of injections

I believe allowing pharmacist to administor vaccines will help in allowing the public to better access vaccination. I hear it over and over from patients that they couldnt or they wont get vaccinated because they dont have the time to wait in a GP office just for the consultation and injection. Other patient that i have suggested to get vaccinated before traveling have forgotten to mention it to their physician and went on their vacation without the necessary vacination. It will also make it easier for the patients and physicians To store vaccines as patients dont have to worry about storing vaccines at the right temprture until getting injected.

I am extremely excited to hear about, and undoubtedly support for various reasons, the proposed amendments to the Pharmacy Act that would enable pharmacists across Ontario to provide vaccinations for a variety of infections and diseases.
With the approval for RPh administered flu vaccines, pharmacists have already exhibited their ability to perform to the standard required to provide such a health service. The program ensures that pharmacists are well educated through "OCP-approved pharmacist injection training" and the maintenance of valid healthcare provider CPR and First Aid certification, ensuring public safety and protection in the provision of vaccine services.
If the proposed amendments were to occur, I feel it would be a great benefit to the Canadian Healthcare System and Ontario LHIN's, but most importantly to the Canadian population, especially those located in rural areas. Patients would be able to receive their immunizations (for school, work, travel, general health, etc.) at their local pharmacy, contingent on the pharmacist being fit to perform the immunization, and in some rural areas a pharmacy may be more easily accessible than a doctor’s office. Additionally, the amount of doctor visits would decrease reducing congestion related to vaccines, albeit by a small amount.
Furthermore, pharmacists resemble a first-line support for patients and enhancing their scope of practice to empower them to provide more of a support is in the best interest of patients and the general public. This scope of practice enhancement also supports the shift in the pharmacy of pharmacists' professional focus toward more cognitive patient-oriented functions. As well, with a greater number of healthcare professionals qualified to provide vaccinations, there is an increased net of safety for public protection in the event of a pandemic or epidemic crisis. This idea cannot be better exemplified than through the H1N1 incident. Had a vaccine been available during the early days, it would have been vital that it be distributed as quickly as possible to reduce the number of effected individuals and potential deaths.
Finally, the only reason I feel anyone would oppose such a progression within our healthcare system is due to the fear of change and the conviction that such practices should be left up to a doctor, or that something will go wrong. Well, registered pharmacists have been performing vaccination injections and nothing has gone wrong! Healthcare should always be progressing and adapting to support the consistently evolving needs of the public, and if more healthcare providers are willing and able to provide an increased measure of essential services, then it is in the benefit (beneficence) of the public, we must respect patients' right to choose where they would prefer to receive their vaccination (autonomy), and to oppose could do harm (shortcoming non-maleficence) to those in areas where a doctor may not be readily accessible.
In closing, I look forward to the new amendments to the Pharmacy Act and ecstatically support the enhancement of pharmacists’ scope of practice and thus their promotion within the Ontario healthcare sector.

I don't believe it is a good idea. I work for a chain store pharmacy. Quotas will be added for the new vaccinations! Lets get back to what were supposed be experts on, rather than running around to find other things to do

It is definetly a No unless another regulation comes along with it to provide more Tech hours.We are already overwhelmed with Flu shots and I strongly believe travel vaccines should be given by a doctor or a special training has to be provided for the public safety

I am licensed in Alberta and Ontario and have been practicing in Alberta for the last 8 years. In my workplace we have a certified Travel Pharmacist and so have been administering and prescribing these vaccines and more for several years. Yes it takes time but it is of immense value to patients. I also believe that pharmacists do a much better job of following up with callbacks and reminders to ensure patients receive their full injection series in the appropriate timeline, leading to fewer incompletes. Most physicians now just refer patients to the pharmacy as they have no time or background for travel health and simply want notification of a complete series. The flaw in the system is that Public Health here in Alberta do not accept vaccine records from pharmacies and so the official patient record at Public Health is incomplete. I would urge Ontario to ensure that Public Health accept/require records from pharmacies.

I am all for expanding our scope to include more than just the flu vaccine, but I do have some reservations. The ability to have pharmacists prescribe all of the entities would be logical - how exactly would we be alleviating the burden on the healthcare system if we still need to send the patient to the doctor for an Rx? This would require certification to acquire appropriate prescribing authority. In addition, I feel that travel vaccines (both prescribing and administration) should be a specialty, requiring even more specific training. BTW where are the B12 injections?? I am comfortable with having properly trained interns and registered pharmacy techs administer injections, but not pharmacy students. More stringent requirements for a private and professional area to administer all injections should be enforced. Finally, I have found it a challenge to give flu shots on a "drop-in" basis; staffing and injection appointment scheduling should be carefully evaluated at each workplace. Last but not least, adequate and appropriate compensation for these services should be established beforehand.

Without any decision-making role, this is just another technical function for pharmacists--only slightly more challenging than "count,pour, lick and stick". It is, however, a big win for pharmacy retailers--more customers in the store buying groceries. It's a win for the government--pay pharmacists less than MDs for same service and free up MDs to deal with more complex issues. It's a win for patients--very convenient, especially when pharmacy retailers invite them to drop by anytime, no wait required. And finally, it's a win for pharmacy students/interns who would otherwise learn injection techniques in a 2nd year course and not practice it for 2 years or more; now they can practice while supervised by an experienced pharmacist.

Although I do agree with the expansion of pharmacist's role. Vaccinations are a technical duty, it anything we should be looking at pharmacy technicians, students and interns should be given the authority to provide vaccines while pharmacists should be given the authority to prescribe the vaccines.

This expansion makes perfect sense. As others have stated, the technique used to administer non-influenza vaccinations is no different than what we are already used to doing with the Universal Influenza Immunization Program, and both IM and SC injections are taught and tested in the training programs we complete to earn this authorization. I am confused why so many respondents are resistant to students and/or interns being able to inject, as they receive the same level of training in this as we do. As long as the pharmacist determines the clinical appropriateness of the vaccine for the patient, the administration itself can be just as effectively performed by a student or intern under supervision. Student immunizers have been successfully utilized in the United States and other Canadian provinces without any problems. I also disagree that more training is needed for us to be competent to administer travel vaccines. As stated above, the administration technique is generally the same no matter what is in the vial, and we are already responsible for determining appropriateness and being aware of the indications/contraindications/adverse effects in order to perform our professional duty while dispensing it. After this assessment and patient education, administering it is the easy part! I can't wait until our scope is broadened to all injectables for this exact reason. There's no reason why we can't do it when other jurisdictions have successfully had pharmacists, students, and interns administer a broad range of vaccines and non-vaccine injectables.

Just like with Flu vaccines, pharmacists will easily be able to take this opportunity to help their patients. Right to prescribe vaccines, monitor lab tests & follow-up as well as minor ailments prescribing (e.g. Canker Sores) would be very helpful for patients specially reducing wait times in ER in a rural area.

I believe that adding the proposed changes to the Pharmacy Act will definitely enhance the profession. I think it is a great idea. However currently Pharmacists are engaged in two main aspects of pharmaceutical services. 1. Clinical Services and 2. The expanded scope of practice. In order for this to work more Pharmacist assistance and overlap hours would be required. If this service is added without any support then this would undermine the quality of patient care.

I disagree with expanding the type of injections pharmacists give outside the flu shot. Giving the flu shot already shifts additional workload on the pharmacist, and giving travel vaccinations would further increase the work load, especially if it is on a drop in basis.

There will be remuneration for this, but this does not directly go to the pharmacist. I may support this if some of the remuneration goes directly to the pharmacist, since this is additional work for no increase in pay and the pharmacist also has to manage all the other areas of the pharmacy.

Ideally this should also be the case for other expanded scope activities, such as for flu shots and even medschecks.

Having greater injection privileges will enable pharmacists to have the unique advantage of delving deeper into the patients health care and making a difference. As with flu vaccines - this aspect of patient care, gave us the ability to engage our clients at a higher level of patient care. With the expansion of more vaccines, it seems to be a natural transition towards enhanced patient management. I believe that pharmacists should have prescribing authority for vaccinations.

I completely agree and all for the changes to the Pharmacy Act as it will enable us to enhance the care we already provide to our patients. I always get asked why we cannot provide vaccinations or b12 injections, which I think should be added to the list. Furthermore, I also believe we should be able to prescribe these vaccinations as well as minor ailments therapy, and I am willing to undergo training if deemed necessary. I think pharmacists have the knowledge already to go ahead with this.

I would be against adding any further vaccines to the expanded scope of practice for Pharmacists for the following reasons. If patients are going through the trouble of getting a prescription for the proposed vaccines, they should just get vaccinated by the physician while they are at the office. You should also ask yourself if Pharmacists really have the time to do this, as well as everything else they are expected to do safely throughout the duration of their shift. I believe the answer is no, as most Pharmacies are staffing themselves cheaply, there is only ever one Pharmacist on shift at one time, in most cases. Until you propose changes to how many Pharmacists are looking after a set number of prescriptions over a set amount of time, I would say no to this proposal.

I totally agree with you! But, there are ways we can make it happen. Simply rising the professional fee can change the total scenario from "not-a-fit" to "perfect-fit". Pharmacies can use the money to run vaccine clinic with dedicated staff pharmacists once a week. Its not only convenient but also safe. Clinic is a good idea because, we need other staff support in case of emergency.

I believe it should open up. We have successfully administered flu vaccine for the last 2 years and it has not been a problem. I think allowing us to administer the other vaccines would hugely benefit our patients. I saves them from having to get the vaccine from us then make an appointment with the office then scurry back there to get the shot.

I really welcome the change
I am administering these vaccines under medical directive-direct order from the relevant physician but some physicians do not understand the procedure and are not ready to part with the delegation plus it is a time consuming procedure The amendment will definitely make positive difference in the patient care and will project positive image of the pharmacist in general I am personally happy about this amendment

Absolutely scope of practice for pharmacists in Ontario needs to expand to help reduce burden on the health care system and expanding injection services only makes sense. In our practice we are already doing several of these vaccinations under physician medical directives and the service is well received. Uptake would be even greater with reimbursement through OHIP, similarly to the influenza vaccinations. I would also like to see Vitamin B12 added to the list of injections. The ability to prescribe certain vaccinations would also be a nice addition in the future.

Good Morning
It’s a great idea . However . The Big Chains have downloaded soooo much on the pharmacists and
techs .
However . Big Chains have taken away Hours .
More Mistakes are being made . More Stress added on to everyone .
The flu vaccine season is a Zoo for everyone……pharmacists and More so the Patient . Especially
the young ones . Great 1st impression for an already frightened youngster .
Unless Big Ivory Tower Chain Execs look at the patients rather than the bottom Line , the Pharmacist
isn’t really a Professional as often is believed in the Chain of Health .

Its about time to bring Ontario Pharmacist in line with the rest of Canada as far as vaccination administration is concerned. Why not take the lead initiative and be able to prescribe and administer, bringing skill level up to be able to do it.

It makes sense to expand beyond flu shots.( I would delete the injection for yellow fever.) I am concerned however about being only one person in the pharmacy on a weekend and expected to administer vaccines by the retail chain. It should be mandatory that if vaccines are to be given, that at least a pharmacy clerk or technician should be working on the same shift. It was very difficult giving flu shots when the phones were ringing and people were at the counter. That was only one vaccine. When you are dealing with various different vaccines, it makes things more complicated and increases the potential for error if you don't have backup personnel.

I am in favour of anything that helps increase the number of immunizations given, particularly those that are part of the routine immunization schedule.

I do have concerns about giving live vaccines in a community pharmacy. Patients are more likely to have an immediate reaction to a live vaccine. Do we have the knowledge, skills and safeguards in place to accommodate for this eventuality?

Travel health is a specialty area. Will pharmacists be able to issue a Yellow Fever certificate? How will patients determine which travel health vaccines they need? Will they still visit a travel health clinic (where vaccines are routinely given at the same time as the consult) and present to the pharmacy with a prescription or will pharmacists be able to prescribe? If the latter, I agree with what many others have said: further training of the pharmacist should be required to ensure expertise in travel health and a mandatory consultation with the patient should take place first. There would have to be some kind of remuneration for this consultation. Currently patients pay out of pocket for consults at a travel health clinic.

I agree. The influenza vaccination program is proof that the public appreciate the convenience of pharmacies offering this service. They also cannot understand why a pharmacist cannot inject other vaccines. A pharmacist who has the credentials should also be able to prescribe travel vaccines and administer them since there is such a need in many areas for this service.

It does make sense that pharmacists who are able to provide one type of immunization via injection be able to provide up to 13 others. However, I believe that additional training/study should be undertaken by those pharmacists who wish to provide all immunizations as travel medicine is a highly specialized field. Also, one should consider that providing flu shots is always IM, whereas when providing multiple vaccines, one should be clear on SC vs IM vs co-administration, timing, etc. So perhaps an online training module re: the specifics of the added immunizations be required. I also think that only those pharmacies who have a private, enclosed office/couselling area be allowed to provide such services to allow for the consultations that should be required prior to administration AND the privacy to administer the injections. Be aware that BigPharma is likely to run willy-nilly with their quotas if this expanded scope is just 'tacked' onto the current UIIP/injection training requirements.

I agree with inclusion of all vaccines.
However, would want discussion re: vaccines which are low use/ difficult to access (e.g. yellow fever & rabies). One of the concerns with increasing access to vaccines is that supplies may be spread out across the province and we would not want vaccines with limited supplies to be in a pharmacy and not be used. It is a concern that needs to be considered at frontline and not at the regulation level.

As a pharmacist I would agree that we should be able to inject these common vaccinations. It should be also expanded to include vitamin b12, prolia, and other common injections as a don't see any difference. Other provinces have been allowing pharmacists to administer these vaccines and Ontario should be included. Thanks

I think this is a great incentive for pharmacist to add value to their services. This itself - as a stand alone service may not be a profitable venture - however as a part of a - package eg care plan , MTM plan this could offer more add on value to various demographics. Opens up space for - new business and practice models , Looking forward to more expanded scope of practice.
Erring on the caution side - how will OCP maintain the integrity of this service. The last thing we want is that the expanded scope of practice is approached with the same mind set as "supply chain operation" where efficiency is measured by - units / time with least man-hours. I believe expanded scope of practice can establish itself better if the constraints of the "supply chain mindset" are removed from it and more - continuity of care plan model is applied.

Great Idea as long as the fee or compensation for the pharmacy or the pharmacist is reasonable .
A flu shot vaccine consumes from the pharmacist time about 15 minutes , from the time you hand over the patient consent form to the patient until you accomplish the task. Guess what other tasks in the pharmacy I could have accomplished during the same amount of time . So if the money is not there some pharmacies may decline to offer this service.

I totally agree the Need of change to the Pharmacy Act by adding injection privileges for Pharmacist. In other Province Pharmacists are allowed to give other vaccine including FLU vaccine .This upgrade will bring focus on patient ease and sharing responsibilities among health care team.

I completely agree with this comment "Pharmacists are already overwhelmed with the workload and expanded vaccine services would create additional pressure. The new burden is going to negatively affect our focus on dealing with Rxs and the associated drug related problems."

NO. Although do-able, it puts a strain to an already busy and understaffed competitive community pharmacy environment. As an independent pharmacy pharmacist, it may be good but most community pharmacists work for chains and the environment is Already stressful! We do not need another reason to drop what we are doing to do vaccines, on top of flu season! If we lived in an ideal world, ocp should set regulations to ensure that chains don't stretch staff so thinly that it risks errors happening. Once adequately staffed, Yes- introduce more expanded scope. But right now, many chain pharmacists are burnt out already!

I almost support the concept, and would enjoy being able to offer this to my patients BUT I am convinced that working for the chain drug store that I do today this new "duty" would probably make me want to leave the profession . The stress level at store level esp at flu season is something next to terror at times. The chain stores have one thing in mind and its not fostering a professional environment. Unless the college can somehow come with rules that would allow me to do this in a professional manner, rules the chain management would have to follow-- I would prefer not to do any more injections

Although this change would benefit the health system and patients alike, there would be more pressure on pharmacists to carry out extra tasks without receiving support (ie more tech hours) from owners and head office. As a result, pharmacists will be more likely to make errors that could compromise patient safety.

Yes. I totally agree. Actually that issue became now every day question from our patients. This will also improve providing more patient care by the pharmacist. Also will open new channels for optimizing professional services.

This is the next step in the expanded scope. I agree Pharmacist's intern should be allowed to give these vaccinations, as they are well qualify. Not very sure of the Pharmacy student.
Do we have to inform family doctors of every vaccinations given? In my opinion, this adds to the workload that is already overloaded. What is the added value (as per positive patient outcome) of doing this? These prescriptions has to be written by family MD's. before we can administer anyways.

As a pharmacist I do not think that we should be administering vaccines. First of all I don't think it is safe because most people do not want to wait at the pharmacy for 15 minutes after getting their injection to make sure that they don't get an allergic reaction from it. Second, giving an injection is a technical role which I think is a waste of a pharmacist's time that could be spent counselling patients, assessing drug interactions, making pharmaceutical opinions, and the many other critical thinking tasks that we are trained to do.

I strongly oppose this change as I feel that the pharmacists are given enough of the burden already with all the extra work imposed on them, yet all the funding cuts are making the community pharmacies understaffed, resulting in longer waiting times for prescriptions and I do not see how this will benefit myself in any way. I prefer to have these injections administered in a doctor's office or a hospital. Thanks!

I think it would be an appreciated advancement to the profession and also the pharmacists to take this roll.
Furthermore, pharmacists should be able to prescribe minor aliments to the public as needed.

If we are licensed and capable of administering the flu vaccine, then of course we can administer any im or sc vaccine. I believe that certification in travel vaccines should be mandatory, however. The OCP could mandate a specific course offered by the OPA which could be designed by experts in this field.

1) I think this is a great way for moving the profession forward. However, if the cost of administering vaccination is just like flu shots then it is not worth it. The cost of vaccination administration should be at least $20.
2) I think this is a great way for student learning. However, the reality is that pharmacy owners/associate/managers use them to make money, just like they do for MedsCheck. They have dedicated student/intern who only focuses on these services.

This is a great amendment to the Pharmacy Act and would enhance care pharmacists provide to patients. Pharmacists have already completed the training to administer flu vaccines and it makes sense to apply it for other vaccines as well. With proper training for students and interns, I am looking forward to them having the opportunity to administer vaccines as well. I hope they understand fully how to administer before administering to the public (as is required in the amendments) and appreciate enhancing their knowledge for their future practice.

While it is a great step forward. The new regulations still ignore the Drummond Report. I would recommend adding more vaccines that actually would matter to the patients of the province. (Tetanus Vaccine access is a must ) while yellow fever benefits so little patients

I am happy they are expanding out scope for injections, however I think it should be publicly funded like the flu vaccine is. It is also good they are letting do zostavax, since we learned both intramuscular and subcutaneous injection.

In theory, this is a step in the right direction for the profession of pharmacy, however this may add too much to our workload. Why is it the responsibility of our profession to lessen the burden on other professions (physicians)? When surveyed, pharmacists frequently say that "time" is the biggest barrier to completing their objectives. How are we going to find the extra time to incorporate injecting these vaccines?

This is the logical next step from administration of the flu vaccine and I fully support it. In my opinion, pharmacists, registered interns, and registered pharmacy students (under direct supervision of a pharmacist) should be able to administer vaccines. With that said, the government needs to compensate pharmacists fairly for providing this service to the public.

I agree that this expansion of the vaccine program would be beneficial to the healthcare system. I believe that we have the ability to provide this service, so why shouldn't we? As for concerns raise by some about the burden this would put on workload, if there is an appropriate compensation model in place for providing this service, pharmacies should be able have additional pharmacist support to enable this service without affecting workflow. This may also be an opportunity for corporate pharmacies to review their workflow model and attempt to optimize the scope of pharmacy technicians. As for the students and interns, yes they should be able to inject once they have the training. This should also be incorporated into their practical rotations in community pharmacy. How else are they supposed to learn? Nursing students are able to practice within their scope and perform injections, blood draws etc. So why not pharmacy students?

I would not be in favour of adding new vaccines for pharmacists to administer. This adds to the workload of pharmacists without any additional support from management. Please stop downloading the work of doctors onto retail pharmacists who are squeezed for every second by checking prescriptions, answering OTC questions, doing Medchecks, giving flu vaccines without any additional help. How can they keep doing more and more?!

I am all for extended scope of practice for pharmacists, but this should be compensated accordingly. I consider that pharmacists are treated as a cheap way of saving money for the government and adding more services to the already burden pharmacist will only increase the chances of mistakes. I would like to see first the pharmacists being compensated for services we are already providing for free- over the counter consultations- and then maybe it will make sense to add more services...

this is going to be the one of the great way to help patients.. but there are few drawbacks especially for the pharmacist who are working in the chain retail pharmacy. as if this rule comes into effect, they are going to give the targets for the pharmacist like med reviews and flu shot, which is very frustrating ... there is only one way to prevent this is, the pharmacist who is providing the service should get reimbursement for that and not the company as the pharmacy is getting the money for dispensing the medication.. pharmacist is putting all the efforts for doing this vaccine and medreviews and what not so they will be reimbursed and not the company... hopefully you people will think about it saves the sinking profession ....

I am not injection trained but agree with comments below about adding more workload to pharmacists. The college should take an active role in ensuring proper working conditions to ensure safe injections for patients. I still have concerns over anaphylactic reactions occurring in a retail pharmacy away from proper medical help but I actually haven't read of any issues with the flu shot so maybe I am too cautious. I do not agree that pharmacists be allowed to prescribe drugs for injection.

I agree with the proposed changes and would add that Pharmacists be given the right to prescribe these vaccines. As many regulated professions can now prescribe it is time that a choice be made. We can no longer remain lukewarm on this issue of prescribing. If the issue is to facilitate access to care then facilitate it, don't complicate it.

I think it's a good idea, but we really need to advocate for Pharmacist prescribing priveleges (and not just for vaccines). In addition, why place such strict limitations on what we are allowed to inject? Pharmacists in my area are already starting to lose jobs to Pharmacy Techs; we need to do more, and fast, to start advancing our role or we're going to have a surplus of new grads unable to find adequate work with $100 K in school loans. Another question I have is, what can a Pharmacist do if a patient has a severe anaphylactic reaction (other than call 911)? Should we not have authority to prescribe and administer initial treatment eg. epinephrine? I realize it's a rarity, but it would be unfortunate having to wait for first responders before anything could be done.

I believe expanding our scope of practice in the manner described is a step in the right direction but I would have liked to see some medication administration added as well (eg Prolia, B12, Humira). In my current practice, I inject via medical directives and direct orders both vaccines and medications via injection and the benefits to adherence are definitely enhanced in both cases with my doing so. I fully support the College in this first step and OPA on the reimbursement side of it. As to students and interns, with the same injection training as part of their current curriculum, it is logical to allow them to practice this skill during their on site training as it is all the other skills they are developing towards licensure.

Pharmacists have already proven the value by administering flu shots. Addition of vaccines, b12 would be very valuable to patients. It would be worthwhile to let pharmacist prescribe too as patients time will not be compromised.

This is a great news. I'm looking forward to inject these vaccines. I wish if Ontario government could allow us to inject all type of I/M or S/C injections. Having said that it's a step toward the right direction.

I am concerned about the pharmacists' time and cost involved. Clearly, some of the vaccines listed need considerable assessment and documentation. A significant increase in professional fee is needed to make it sustainable.

If the fee is increased, community pharmacies can run dedicated vaccine clinic days with dedicated pharmacists. Otherwise, it does not fit in the current workflow of a community pharmacy.

I think our scope of practice should be expanded to include other vaccinations. I have had many patients ask me to administer their Zostavax, Twinrix and Prevnar. I have had to obtain a prescription authorizing me to do this from their MD. I actually had a physician contact me to ask if I could administer Zostavax for her.

I think this opportunity is fabulous but I don't think pharmacists should have to stop whatever they are doing to administer vaccines. I think they should have flu clinics in the fall that they can adequately staff for and all other vaccines should be on an appointment basis - as well to staff appropriately.

The changes for us to inject more than the flu vaccine will be happily accepted by pharmacists and patients. It's time we provide a better service to the public and catch up to the rest of Canada. Our patients deserve better access to disease prevention. This will also free up our physicians' time to provide better care. This is a necessary addition to our profession as we demonstrate our advanced skills!

I beleive that these changes will benefit the public since the most accessible health care professionals are the pharmacist. So the public will be easily get vaccinated and get protected from many preventable diseases in more convenient way which will decrease the burden on physicians. This provides a good example of interpersonal collaboration. In addition tothat. I also recommend, pharmacist shoukd get opportunity to oreacribe for minor ailments as in other products, this will decrease a huge burden from emergency toom admissions thus save provincial funds.

I believe that the intended changes to the Pharmacy Act with respect to the expansion of the injection privileges for pharmacists would greatly enhance the care we provide to the public and would be a great step in strengthening Pharmacist-Patient relationship. I have been already administering Flu vaccines and it totally makes sense to me that if all other appropriate vaccines can be given by the pharmacist, then there is no need to take physician's time. I believe it would greatly help Physicians with them using their valuable time for patient assessments and treatments and most important is, it would definitely be more convenient for our patients.

I am not interested in expanding vaccination services. Corporations are raising the expectations regarding these technical services without providing any more staff and it takes away from our clinical services in addition to the added stresses on the pharmacist. Flu shot season is a very stressful time of year with many days going without a break in a long shift. Our well being as professionals in addition to the care provided to our long term patients is at risk. Most doctors no longer administer the vaccines..so I don't think that this will free up their time!

this is very beneficial for patients who have hard time getting a doctor's appointment to get their shots either vaccines or vitamin B12.

I DON'T AGREE that students or interns can administer any injection under the supervision of a pharmacist... it should be their own responsibility dealing with needles and ensure patient's safety and well being so it is better to wait until they are fully licensed otherwise they should be given the option to do it or not under their own liability and they must get patient's consent.

Also we need to know more about the billing how will this be different than the doctor's office ? are patient going to pay get their shots? are we to bill ODB , get $7 / injection?

Long waited step.However , It is a good step on the right track , I think pharmacists also should have the right to prescribe vaccines. Specially if it is an adult optional vaccine.Why should I wait for a Dr's Rx for travel vaccines for example. Why can't I write an Rx for OTC vaccines to allow pt to get it covered by his insurance??
I still don't understand why Ontario is not on the same level with these legislations as other provinces.
However, there must be a good compensation for time used to perform these activities, otherwise it will not be practical.

All proposed changes are long awaited and make sense. Hopefully pharmacist would get fair compensation for the services. I believe we should get at least 70% from the compensation that was given to physician for the same services. I believe we can do more than administering vaccine and I can see pharmacists manage minor ailments to ease the pressure on the healthcare system and emergency rooms. Again, I am expecting fair pay for pharmacists for the services they provide.

Why should pharmacists settle for LESS than what is paid to doctors for the same service? 70% is inadequate; the convenience factor alone justifies the full compensation paid to doctors. Same service, same risk, same fee.

I believe the intended changes will be a great benefit to the public due to ease of access. But I also believe pharmacists should be able to ask for blood work and prescribe travel vaccination. It would complete the picture and make like easy for the patients. We are qualified for more scope than we have at the moment. If some are not comfortable, we can have more courses to qualify. I don't understand why other provinces are so much ahead of us while Ontario is the one that needs it most due to a large population.

I feel that we should start seeking injection authority for registered technicians as part of this scope of practice expansion. Pharmacists should definitely be involved in the cognitive components of recommending (or hopefully prescribing) and confirming appropriateness of therapy, however the act of administering an injection is a technical role and technicians should be allowed to perform it as a result.

I fully support the implementation of vaccine administration at pharmacies. From a patient convenience and cold-chain perspective, it makes complete and common sense that the place where the patient picks up the vaccine is where it should be administered. This makes for more efficient Ontario health care delivery. Pharmacists have the necessary background training (6-8 years of science , rph + injection course) to qualify for this responsibility.

Also, travel medicine is an excellent area for pharmacists. Community pharmacies would make excellent travel health centres for Ontarians because of accessibility. I think, after extensive and evidence-based training, pharmacists should be able to prescribe some medications for travel. Pharmacists should base their decisions to prescribe on patient care and not at all on business motives.

I think these changes would be beneficial to the Public but at what cost to the profession? Pharmacists should be compensated for these extra services but this instead will be another added pressure to practice. I do believe interns should be allowed to practice as the final rotations PharmD students do already have them "ready to practice". Students - no. They do not have the clincial or practice skills to deal with the various patient populations,

ABSOLUTELY NOT. Let the Pharmacists do their jobs and the trained Doctors and trained Nurses do their jobs. Enough with the "cross contamination" of professions, jack of all trades crap. There is a reason for specialist. Doctors' offices and hospitals are equipped to handle health care and any issues that may arise. This is just an easy way for Pharmacists to increase their bottom lines. The majority of "yes" responses are from Pharmacists who will profit from this arrangement. THINK ABOUT THE PEOPLE, THE PUBLIC, who will be asked to use these services.

Many vaccines contain egg white . It's reaction would be just like as in organ rejection,that is with micro hemmorages,tissue reaction,inflammatory and potentially deadly. EpiPen will not resolve the problem . Pharmacists can not handle this issue so better refrain from it!

Fully support expanding the list. Support interns being allowed so long as they have had the training. Do not support students being qualified, unless they have been trained AND in the final year of University (not hard and fast about final year) depending on course format.

This is a logical step up from giving flu vaccinations.
Get asked all the time if we can inject vaccines. This will be so convenient for patients and will encourage greater compliance. We have the training.

To begin, in past consultations, the minutes of Council have reported upon the numbers of responses received. As such, many of them appearing here appear to be very very similar; perhaps repeat posters, perhaps "flooding" to try and increase the numbers on one concept so it gets favoured consideration by the College? One hopes not.

The response from a public member (#118) is far too specific in terms used, references, etc. to be an "average" member of the public. It sounds more "administrative" or "outside professional". But further comments are warranted:

1) While many favour this "advance" in practice, given the vaccines being considered and the acumen of the average community pharmacy, do we really think that these vaccines will be "in demand" on a regular basis from such pharmacies? That cuts two ways: first, not being as busy as some might suggest it could be; and second, how does a pharmacy that only gets the occasional request for certain of the 13 vaccines keep them in stock so they don't expire before being needed?

2) Will "convenience" be realistic to the patient? That is: if a prescription is presented for one of the vaccines and it's not in stock, or has expired, there will still be a wait and re-visit by the patient when it arrives in the pharmacy. This needs consideration.

3) Given the "live vaccine" aspect that others have commented on, it is imperative that rather than "grant approval to the pharmacist" to administer, the OCP needs to first make sure the PREMISES has a designated area that meets its specifications -- not the general dispensary area where multiple patients sit beside each other as they wait for their shots (first-hand experience as a patient at a prominent pharmacy chain administering the flu vaccine). If the premises is not set up to provide this designated area, the pharmacy should not be allowed to participate (same manner as being properly outfitted to do non-sterile/sterile compounding). It is no good to assume the premises will meet requirements, then find out it does not and "pull" the ability to administer vaccines. It must be kept professional, and the designated area will go a long way to achieving that goal.

4) It must be mandated that any administration of vaccine be reported to the primary care physician after (to cover situations where the patient is not a regular patient, as well as in regular patients), so that the healthcare file is comprehensive. This will prevent duplication of vaccinations (possibly hazardous) when patients aren't really aware in attending the pharmacy what they may/may not have had in the past. (We base a huge degree of confidence in assuming we shall have a complete record from the patient at time of attendance -- far from realistic). Since doctors bill OHIP and that creates a central record under the Health Card for that patient, pharmacists don't have that benefit. Either it must be incorporated into the process, or duplication could occur when a secondary authority to the physician is allowed to administer vaccines (i.e., no central record access for pharmacists).

5) Extra workload on the pharmacist: hard to tell at this point how many of these new vaccines (if approved) will be required to be administered at the pharmacy, and how often, in order to state that it will create a huge further strain on pharmacists already stretched to the limit, or not. The impact of this action on practice should be monitored and assessed by the OPA, in liaison with the OCP. Since the OCP has a mandate of, in part, protecting the patient interest, certainly increasing the risk of errors in an already maximized pharmacy by increasing workload ought to be an OCP concern.

6) The specific 13 vaccines put forward in "16-HLTC005" (regulatory change to O.Reg 202/94) raises a question as to whether it is that specific that only those listed will be approved (i.e., Hepatitis A alone, item 3; Hepatitis B alone, item 4), or if combinations of the listed vaccines will be permitted (i.e., Twinrix). To avoid confusion, HepA+HepB mixture should be listed as an individual entity, if it is expected that Twinrix is to be approved for administration. (This is a realistic consideration given that individual drug plans are very specific in terms of what vaccines may be covered on a patient's plan).

Although I support the changes to the regulations because it allows our profession to provide better care for our patients, the College needs to protect the public by having additional oversight on pharmacies as a result of these changes. The additional workload that is generated by these changes needs to be accounted for, so that errors due to inadequate resources does not become a risk to the public (e.g. flu shot season was very disruptive to workflow and created some near misses). Dedicated injection pharmacies would be a potential solution to this problem.

In many cases this would not be recommended due to cuts in labor coupled with frequent unreasonable demands to provide services. (E.G. "Your target today is 22 Medication Reviews. You will check 250 prescriptions by yourself as well. You will be allotted 16 hours of assistant help to cover the 12 hour day. Have fun today.") This has been going on for years and is getting worse. As the company's have limited, if any, liability, the onus is on the professional to decide what is an appropriate service. Unfortunately, I am aware of more than one individual that was terminated for not achieving the demanded service quota. There may be a role for the College or Government to ensure minimum ratios with regard to Rx volume or administering immunizations. If we are given support, most pharmacists would have no issue with administering the suggested vaccinations. In the current environment however, I feel that it will make an already difficult situation unmanageable and therefore unsafe.

I believe that the time has come to proceed with this
programme .Everything is in place ,it has been demonstrated that pharmacists can perform this function as well as anyone and there certainly is a demand from the public .Compensation however has not been addressed. I don't think that current rates reflect the actual costs in terms of training and time spent . With ministry cut-backs can we afford to add another public service to an already stressed profession.

I think this is really pushing it and the college is no longer looking at the best interest of the patient given such propositions! The reasoning being that the community pharmacies are highly understaffed due to recent government financial cuts, and the pharmacists are working longer hours with more work. This leads to greater chances of errors and thus increased risk to the patient. During the flu season the pharmacists are finding it hard to manage the workflow, since they are not given the pharmacist overlap or extra staff. If the college sincerely thinks about the best interest of the patient, instead of the push from big pharma, they would not allow such things to happen. Give nurses this job, not us!

I am a little worried for Pharmacist who work for large corperations, currently they are given targets to reach and pushed to get patients to come in to get their flu shots. A great stress for pharmacies under staffed and no hours given for overlap. It is great to see them expand their scope of practice, however, small designated pharmacies who are not so busy would be a better choice. I have been an assistant now for 32 years and seen many changes in the way pharmacies operate, my concerns is for the patient and not the fees we get to render these services.

Having pharmacists able to administer routine vaccinations as per the provincial vaccination schedule will increase accessibility to the public and improve patient care in many instances. Nevertheless, this does not apply to travel-related vaccinations which require a great deal of knowledge and training to know which vaccines are indicated with regard to the health and vaccination history, the itinerary and the nature of the trip. In order to protect the public, travel vaccines and antimalarial drugs need to be prescribed by a physician.

Administration of other vaccines in addition to influenza vaccine make complete sense. Many patients ask for that and we are ready to administer it to them. I think this may be a good opportunity to expand our scope of practice.

I like the idea of having vaccination process more available to the public . On the other hand, I strongly disagree with the Proposed Changes to the Pharmacy Act. I don't see the "administration" of vaccines under the scope of practice for the Pharmacist at all. Prescription adaptation, Pharmaceutical Opinion, Drug Interaction is something that the Pharmacist should deal with. Administering the injections is more for the Nurses.

Would it not be covered under section 4.(1), pgh 2, of the Pharmacy Act?:

(1) In the course of engaging in the practice of pharmacy, a member is authorized, subject to the terms, conditions and limitations imposed on his or her certificate of registration, to perform the following:

Administering, by injection or inhalation, a substance specified in the regulations.

Good morning, I would like to lend my support to proposed changes that would enable pharmacists to administer an expanded list of vaccines. These changes will increase availability of vaccines and reduce demands on other scarce resources (e.g. physicians and nurses in primary care).

My only issue is with administering of vaccines to prevent diseases under which you have listed Tuberculosis. TB vaccines are not widely used in Canada. Are you referring to TB Skin testing? This then is an error in your submission

I look forward to being able to provide more injection services. I feel very underutilized in the current pharmacy situation in Ontario. Prescribing for minor ailments needs to get here soon, and communication about upcoming changes needs to improve.

This extended scope of pharmacy, in theory is a valuable progression for our standards of practice. However, retail giants have taken the care out of our practice, thereby increasing our pressure as a pharmacist. This addition, will become a money grabbing thing for the corporate world. I do not think this is a great idea, considering we are constantly expected to do more, with very little return financially and health based. If this change were to come about, i think travel vaccines should be exempted, and should be solely the responsibility of a travel clinic. They are a speciality clinic for this reason.
Also, if this is truly a patient care incentive, then maybe Ontario should look into giving pharmacist prescribing rights on certain antibiotics. That is a lot more beneficial for our patients, than getting a yearly vaccine done for their convenience.

I believe that pharmacists, once they complete the Injection Training Program , have the expertise to be able to administer a number of vaccinations besides the Influenza vaccine. They should also be allowed to prescribe these.
In addition it makes sense for students and interns with adequate training to be able to give vaccinations as well.

I believe that this is not an ideal situation. I can't believe that ONA is not voicing there concerns over with this, as this is taking away nursing jobs. Pharmacist do not have enough time to do there jobs now so I can't imagine them taking on this task. Who is going to pay for the vaccines that are exposed to cold chain failures as they try to jam as much vaccine into their fridges now? Who is going to be responsible for this. There are so many changes with vaccines, are they going to be educated on proper spacing. This to me is just another marketing ploy to have more customers in there store to spend money. They are not concerned with people, just profits.

I welcome this addition but would like assurances that there are required staffing numbers at a pharmacy in order to have these vaccines administered. A pharmacist cannot be answering the phone, taking cash all while assessing a client and administering possibly a number of vaccines. Although adverse events are rare its not unusual to have fainters, etc- this needs to be accommodated for within the corporate requirements.

I welcome the proposed changes as it will enable public to access vaccination easily. I request authorities to permit Pharmacists to prescribe vaccines as the indications are very clear and well defined.

This is absolutely a move in the right direction. Pharmacists have demonstrated our ability to provide immunizations via the UIIP, this is the logical next step. Further it will very likely save time for both physicians and patients, and opens the door for pharmacists to play a greater role in pubic health and travel medicine.

I strongly believing in capabilities of Pharmacists. They should be involved more in clinical aspect rather than just signing prescription. Administration of vaccines will be a good start towards that and I am in full support of the proposed amendment. I am ready to go for any further training this might need.

this will add to the pressure (ever increasing targets, cut down on assistance and pharmacist overlap hours) and increase chances of medication errors. The college may have to look into and take steps to help ease the pressure from the managements in corporate, banner and franchise pharmacies to achieve targets. The college has to ensure that steps are taken to ensure that pharmacists have the staff support to work in an environment that ensures the safety and accuracy to the public at all times

I believe pharmacists should provide more immunizations. I already do this in my practice through direct-orders from various local physicians. Both patients and physicians have welcomed this service, for the most part. We have already easily incorporated it into our work flow. We also commonly do human papillomavirus and B12 injections, so it would be good to add those to the list as well. I would like to see guidelines for pharmacist providing methotrexate injections, as we get this requested from patients a lot (direct-order).

As for students providing immunizations, I think this would have been very beneficial to my training. See article recently released in CPJ in regards to this, http://cph.sagepub.com/content/149/3/153.full.pdf?ijkey=zDWvOfra0iudlxA&keytype=finite

This may be good for our profession in the future, but in our current "employer market" it as just another task that employers will expect us to perform without any title, recognition or payment. Vaccination is a new science, training, legislation and practise to us. However, employers do not care or compensate us for it. What is the advantage to us as pharmacists in our current overloaded schedule?

I believe the proposed changes to the Pharmacy Act in terms of Administration of Vaccines is a great change to the scope of pharmacist. It will reduce preventable infections and diseases by making vaccines more accessible to the public.

Please request the addition of administration of 14-16 yrs age boosters and HPV vaccines to the list administered by Pharmacists. The administration can be billed and recorded using a similar process to the meds check etc for non ODB clients until the new vaccine recored is ready. The administration of these vaccines by Pharmacists would be much more accessible to the public, no appointments, longer hours, close to home, accessible, and provided by a trusted professional with whom the patient already has an established relationship. The recent events in Waterloo highlight the challenges working parents have juggling life, work, aging parents and getting their kids to these appointments. I personally received a warning letter of pending expulsion for my child which caused me a great deal of distress and making me feel like a bad parent when I was simply overwelmed with the requirements of being a working parent today. It would have been wonderful to go to the local Pharmacist across the road where we get our flu shot instead of making an appointment, using badly need vacation time, driving farther and paying parking. I am knowlegeable about the importance of vaccines/boosters and I had difficulty with the current provision of these services. I wonder how other parents manage.

I believe that it is a high time now that the pharmacists in Ontario should be allowed to do immunizations as well. This will be a great opportunity to develope a professional relationship with the patients.

This would be a good additional expended scope for pharmacists and it could complete the role of pharmacies to become one stop for all vaccine administration and monitoring destination. But funding cuts by the government is a road block, because employers cutting wages, hours, hiring 3 part-time pharmacists instead of one or two full time, to manage the budget, putting more pressure on pharmacists to do more.

I am a retired pharmacist/member emeritus of OCP. I am very supportive of initiatives that further integrate and enhance the pharmacist professional role as a primary health care provider. I would prefer to see more emphasis on promoting the pharmacist's role as expert authority on pharmacotherapy through expanded scope of practice in the area of prescribing and adjusting appropriate drug therapy. Administration of vaccines can and should be delegated to other frontline health care providers who could perform this service in a pharmacy setting to facilitate access fro patients. However, if adding the task of administering vaccines, which in my view is not consistent with nor the best use of a pharmacist's expertise, will serve to strengthen the profession's position on the primary health care team, then the role should be expanded to the full extent possible. I remain concerned that this service will further confuse people about where the pharmacist's true expertise lies. Please work harder to enhance the prescribing role!! At least ensure pharmacists in Ontario are able to do what pharmacists in other provinces are already able to do.

I support pharmacists giving vaccines for travel. The public already expects it. I have had to explain that I am not allowed to give a Twinrix shot because I do not have legislation permitting me to do this.

I do not support students nor interns giving these shots. They need to be comfortable dealing with the public before putting their hands on to patients. The public needs to trust the pharmacy they are dealing with.

The disadvantage of offering more services to the public is that the quality of the core pharmacy services such as catching drug interactions, catching drug related problems in a Meds Check and following up on the problems, may decrease.

I have caught drug interactions, and drug problems from patients discharged from our local hospital, which is top-heavy in registered technicians. Patients in Ontario have already been negatively served with the Chemotherapy fiasco.

Offering more services to the public is a positive, however how do we maintain the quality in pharmacy services?

Last fall our pharmacy gave 800 flu shots. We were so busy that we did not have the time to inform each person's family doctor. The only way doctor's could chart that their patient received the flu shot is if the patient told them.

So now if we expand to Travel vaccinations, how do prescribers know if their patient actually received the vaccination. Will patient's charts in their doctor's offices be incomplete because pharmacy is too busy to send them a fax? How do we close the loop and have prescribers confident that their patients have indeed been vaccinated as prescribed? How do we maintain the quality while having an increased workload?

I totally believe the change is a valuable and necessary. I strongly feel the essential of a mandatory learning modules on the 13 diseases and provision of patients' immunization record should be considered

I am all for administering the more common vaccinations (I.e. those covered by OHIP). Also, any prescription for a vaccine filled at a pharmacy (Gardasil, Zostavax, Twinrix, etc) should be administered by pharmacists- what's the point of filling your prescription but having to return to the doctor's office to get it injected? Not only would that be inconvenient, but the integrity of the vaccine would be jeopardized as well due to temperature restrictions. For now, we should postpone pharmacist vaccine prescribing until appropriate auditing and oversight are implemented. Students and interns should be allowed to administer injections but only according to their comfort level and under direct personal supervision of the preceptor.

Giving an injection is a technical skill not a clinical skill. It is more cost effective to administer vaccines by registered PA rather than by pharmacists. Pharmacists should utilize their clinical skills by checking Rx, counseling and medscheck especially in understaffed pharmacies.Thanks

As an antimicrobial stewardship pharmacist, I believe increasing access to vaccines is an essential component of Ontario's strategy to combat Antimicrobial Resistance. I see no risks or harms assocaited with expanding access of pharmacist-administered vaccinations, based on the experience of other jurisdictions, and innumerable benefits.

Yes, we should definitely be allow to do other injections besides flu. We should have been allowed to do all the I.M injections from the start in the first place. I feel that Vitamin B 12 injection should be on the list as well.
Since the actual act of injection is more technical in nature, I think that pharmacy technician should be allowed to do flu injections given the proper training.
As for students and interns, they should be allowed to do the basic flu injection only after they have been properly trained and have practice I.M. techniques on actual people. ( Passing a course from the faculty without even injecting each other with normal saline definitely does not qualify.)

I believe pharmacists are ready to fully embrace the expanded scope of practice. Being able to provide routine injections will not only alleviate some of the pressures of the healthcare system, but will also strengthen our therapeutic bonds with our patients. Naturally, it seems efficient and effective to allow pharmacists to provide routine injections.

I'm against allowing the pharmacist to administer more vaccines. The corporations and business owners are not creating safe and feasible conditions for us to provide that service. We can't take 15 minute to directly observe a patient after administering an injection. The layouts of the pharmacies are not allowing for it either. As a result, we have increased liability without any support from the college in ensuring public safety and corporations that care only about their bottom line.

Pharmacists are in a position that make them able to inhace the health care. If given this privileg they can make a deference .in my practice we do administer vaccination with medical directive. Patients appreciate this service because of the convince. Saving them time and money.specially that pharmacist is more avalability ( evenings and weekends)

While I think the majority of Pharmacists are quite capable, I believe this would add additional stress and put more load on an already overloaded day. There is always a potential for med errors due to rushing by Pharmacists trying to keep up with an increasingly hectic workday.

I believe that vaccination administration would benefit the patients greatly. I do believe there should be some legislation in place to make sure this is only done by appointment or when 2 pharmacists do overlap . If an adverse reaction were to occur, it would be difficult to manage anaphylaxis as well as continuing workflow and customer service. Many patients try to leave right after you give a flu vaccine, even though they agree at the beginning they will stay 15 minutes to be monitored. Also once corporations start advertising such services they often tell patients just to drop in and get vaccinated with no consideration for extra staffing to ensure patient safety

Our very small town does an excellent job in healthcare. We have a local doctors office with walk in clinic days every week. We have a nurse there that administers immunizations. The access our patients have to the clinic is amazing and should our patients require any vaccines they would be readily available to them. I do not feel that we need to take work away from dedicated nurses and doctors offices who are better able to deal with medical emergencies with a physician on staff versus a dispensary without the physical capabilities of dealing with an emergency nor room to house vaccine recipients who are waiting post vaccination for the OK to leave. In general the vaccines are not needed on a stat basis and the patients could wait for an appointment to receive them. As well we have a health unit close by that also deals in vaccines. They are a wonderful asset to our healthcare team.

Allowing pharmacist to inject ..yes to that . But the added workload especially when most weekend , I work by myself. I can only see myself struggling with the phone, cash, counselling and filling a prescription.

I am reading the new proposals with interest. At my current place of practice, we administer flu vaccines, both in a clinic format & on demand. We also have nursing staff in the building that administer other vaccines as well as flu vaccine.

I have discussed this with some of the nursing staff, and we share some concerns about vaccination records. We both agree that we need a better registry for vaccines - perhaps through public health. We have found omisssions and duplications occur when patients
have vaccines administered at multiple sites - e.g. doctor's office, pharmacy, travel clinic etc.

We pharmacists, as clinicians and health professionals, should have access to a patient's vaccination record (as well as other important health information !!) to be able to proceed safely and accurately.

Pharmacists should be allowed to administer vaccines like those of B12, Prolia ,Twinrix,Havrix,Engerix on top of the seasonal flu vaccine.
Certain travel vaccines like that of Yellow Fever may need special training/ directives.
Pharmacists giving flu shots are required to keep their CPR training updated and are required to administer epinephrine in case of anaphylaxis and all pharmacies are required to have an acoustically secure private area for counselling purposes which usually doubles up as flu vaccine administration room,so what if emergency situation and space is not an issue.
Time is an issue though as there will be interruption in regular work flow.Since 1 pharmacist can do 1 activity at a time so someone will have to wait as error due to multitasking is not an option in our profession.Having said that,it is imperative that we as a profession embrace any expanded scope which comes in our way as that is the only way for the profession to grow , of course we should ask/demand to be remunerated for the same.Since it is not a perfect world everything may not happen at the same time but will happen eventually (fair remuneration etc).Wholehearted participation and enthusiasm for any expanded scope of practice,be it giving vaccines,prescribing for minor ailment etc is very much needed for more such things to come our way and for the profession of a pharmacist to evolve to next level and remain viable in future.

Pharmacies in Ontario were once thought to have the highest standard in Canada - we had then as the the registrar Bill Wensley and then Diana Lawws - we now have a great new Registrar, who offers some really good ideas for us as pharmacists, including some great adaptations
I do not have time to give any more vaccines or to waste my time commenting on these issues. The people who are responsible for administering
vaccines should continue to adminiser them (they get paid more than we do - (so why pay off the organization and hit us for yet another hit) these vaccines.
The College has recently seemed to fail to enforce the rules - pharmacies are required to file Rx's in numerical order - some stakeholders SEEM to have been excused from this requirement - why?????? Should not all pharmacies be required to follow the same rules?? Should not the playing ground be the same for all ???

I do not support the proposed changes to the pharmacy act i.e. administering other vaccines by pharmacists. Pharmacists are already overwhelmed with their work. There are many times pharmacists are stuck working alone without any help. Unfortunately, the average person that drops off a prescription thinks that filling a prescription is a one minute job, and is unwilling to wait because if the do not see a lineup at the drop off or pickup they feel you are doing nothing. Adding this additional responsibility will take time away from our therapeutic check.

I believe that the intended changes to the Pharmacy Act with respect to Administering additional injections by pharmacist is not a good idea. Pharmacists are already burdened with so much work. This is going to take a lot of time from the services that pharmacists are suppose to provide. Unfortunately we are not adequately compensated for administering vaccines and patients are not willing to wait.

Given the current state of EHR, EMR, BPMH, and Pharmacy IT Data inter-operability (connectivity) across platforms to identify, access, diagnose ADR; any suggestion of changes to the Pharmacy Act permitting injection privileges is not only premature but ill advised not to mention the legal ramifications.
Dispensing medication is not the same as administering, and nor does it have the same therapeutic results.
Respectfully, yes, the Pharmacy Act is a living document and as such, needs to be amended to bring it into the IT world of Healthcare but, any delineation of liability is a dangerous slippery slope.
Summarily, Physicians diagnose and Pharmacist dispense-if you want it differently start with the knowledge, qualifications but, before you do that change the Health Act.

I agree with this expanded authority. However, I believe pharmacists should have the database (similar to, but better than, the ONNMS) to track vaccinations. It is extremely important for the circle of care that the primary physician/NP is able to access vaccination database. I also support any future prescriptive authority of these vaccinations, given additional clinical training.

I agree that we should also be able to PRESCRIBE these vaccines especially if we are going to be responsible for:
1. Vaccinating the patient (if we're not prescribing, then how is this so different from getting a medical directive for such a vaccine)
2. Informing the primary physician/general practitioner that the patient received the vaccine (and "details" surrounding this vaccine) - this sounds like a lot added to the workflow.

I think it's also important to recognize that because we will be responsible for injecting this, we will have to educate ourselves MUCH more closely of the Canadian Immunization Guide (especially when it comes to some of the considerations surrounding our immunosuppressed patient populations, and especially when it comes to patients who we do not know very well). It will be so important for us to know what medications these patients are on. I really think pharmacists should be providing these services to patients that we have at least a 3 month relationship with.

I think the language around TRAINING (" The member must possess sufficient knowledge, skill and judgment respecting the substance
to be administered, and sufficient understanding of the condition of the patient, to be able to
administer the substance safely.") needs to be strengthened. While I believe a 4th year pharmacy student on their APPE or final Co-Op rotations or an intern would probably be well-equipped to provide these services, I do NOT believe a 1st, 2nd or even 3rd year pharmacy student would be a sufficiently trained provider of these services.

Training requirements must also be strengthened, because it will be important in the course of injection training courses approved by OCP that pharmacists are educated ON these vaccines that we will have to provide, because I'm quite certain that if you were to ask someone what the precautions, warning, common dosing, etc. surrounding a vaccine such as the Japanese encephalitis vaccine, very few pharmacists would be able to give you a sufficient answer.

It's not just sticking a needle into a patient, we are being tasked with a lot of serious responsibility here. And it is important that the OCP support members to fully rise to the occasion.

I wonder if that can be clarified to SENIOR pharmacy student (i.e. 3rd or 4th year). The training part must be stressed.

University of Toronto students get a 2nd year injections information course (although this does not include ANY injections of live people, mind you). I think a 3rd or 4th year student, then (especially during their APPE year) should be well-equipped to provide injection services.

Just want to avoid having a pharmacist train a 1st or 2nd year student on the job in order to add to their bottom line.

Please find below the submission from Novartis with regards to this request for feedback to the proposed legislation. I think we have picked up an important nuance that needs to be included in this review and amendment.

Currently, pharmacists may administer the influenza vaccine within the context of Ontario’s Universal Influenza Immunization Program (UIIP). These proposed amendments to the Pharmacy Act Regulation support the Ministry of Health and Long-Term Care’s promise to provide Ontario’s patients with an improved healthcare experience. The proposed changes would allow for the administration of additional vaccinations for 13 diseases that are preventable by vaccines.
The Ontario College of Pharmacy and Ontario Pharmacists Association have asked for feedback on proposed amendments to the Pharmacy Act Regulations that, if approved, would authorize pharmacists to administer vaccines beyond influenza vaccine.

Novartis is pleased to provide feedback to the proposed amendments to the Pharmacy Act Regulations. Providing safe, effective and accessible vaccines to the public is a central theme to achieving a high standard of health care in Ontario. Currently there are many vaccines that have been approved by Health Canada that are not funded by the government, that individuals may choose from to protect themselves. The addition of vaccines in the 13 disease areas into the scope of pharmacist practice is an important step towards allowing greater access to the public of those vaccines that remain approved but unfunded.

Influenza has long been recognized as one of the most challenging vaccine programs to delivery effectively and an important first step was achieved by involving Pharmacists in the UIIP program. It is important to note that the UIIP program is restricted to only those vaccines that are funded by the Ontario government and for those individuals that are deemed eligible. Currently it is not within the Pharmacists scope of practice to provide an influenza vaccine that is approved but unfunded, while physicians can. Similar to the 13 new disease areas, many influenza vaccines are approved but remain unfunded.

Novartis would like to provide the feedback that the amendment to the Pharmacy Act be expanded to include all vaccines that protect against Influenza (not just those covered by the UIIP). This would then ensure that Ontarians would have access to all vaccines in the 14 disease state areas that are both funded and unfunded.